top of page

Fire Retardant Chemicals in our Furniture and Fabric

Article written for the Clean Air Programme - a government funded programme aiming to bring together leading researchers from atmospheric medical and social science on air pollution.


OPEN LETTER written to the MP for small businesses Mr Paul Scully

Upholsterers do please click this link and sign this open letter

Please read, consider, sign and share.



and for those who would like to read more.......


Explanation of the open letter to Paul Scully, minister for small businesses, 2 April 2022 with each point in the letter explained or referenced.

1. Upholsterers and the general public are at risk because of the excessive quantity of fire retardant (FR) chemicals in our furniture, bedding and fabrics.

(A) A study on carpet installers and other workers concluded that they were exposed to fire retardant chemicals and that these chemicals were present in their bodies. Upholsterers were not one of the businesses included in the study.

{Worker exposure to flame retardants in manufacturing, construction and service industries, Estill 2020}

(B) The UK government in 2019 undertook an environmental audit which concluded that fire retardant chemicals were of concern to human health. They are persistent, bioaccumulative and toxic, some kinds are also classified as carcinogenic, toxic, disrupting the reproductive system, some disrupt the hormone system..”

{UK Parliamentary Environmental Audit: Toxic Chemicals In Every Day Life 2019}

(C): This study concluded that there are FR chemicals in our house car and office dust.

{Concentrations of brominated flame retardants in dust from United Kingdom cars, homes, and offices: causes of variability and implications for human exposure: Harrad et al}

(D): This study concludes that we breathe in FRs and they permeate our skin.

{Respiratory and dermal exposure to organophosphorus flame retardants and tetrabromobisphenol A at five work environments. 2009 Makinen}


(E) This study looked at the occupational health risk of workers dismantling electronic goods that had been treated with FR

{Exposure of Canadian electronic waste dismantlers to flame retardants, Miriam Diamond }

So when this scientific data is out there why is nothing being done? The challenge for the scientific community is that health risk limits or health base values have not been defined. e.g. if you have more than xxx of this chemical in your body then that is defined as problematic. The other challenge is that the chemical companies manufacturing FR chemicals regularly change the products without notifying the consumers/scientists of the new formulations. This constant flux makes base lines difficult to measure.

Source **

2. The 1988 Furniture and Furnishings (Fire Safety) Regulations force the UK to soak our products in more FR chemicals than any other country in the world

A: Because the UK has a match test in the 1988 regulations, the fabric is treated with more and more FR chemicals until the fabric covered foam does not ignite when exposed to a match. The furniture manufacturers could comply with the current legislation by using a natural top fabric and a barrier cloth or other less toxic method, but they choose not to because it is a cheaper manufacturing process using FR backcoated fabric. This standard only protects against a small open flame which means the chemicals do not provide meaningful fire safety benefits in real world upholstery fires. These are mostly started by a smouldering source such as a cigarette.

B: The EU has not adopted the match test. It is important here to explain that the match test in the UK involves a live flame being applied to fabric laying over highly flammable foam. Foam is itself petroleum based (so is highly flammable). In the US they have adopted the smoulder test. This involves a smouldering cigarette lying on fabric which lies on foam for 45 minutes. This smoulder test can be passed without the use of flame retardants by either using a flame resistant fabric that withstands ignition in the 45 minute time period or in case of a more flammable fabric by using a non chemical interliner. 

Environmental Audit page 24

“The UK and Ireland are the only EU member states to have additional national fire safety controls on domestic, upholstered furniture. This requires products to pass ignition (match) and flammability (smoulder) tests before being placed on the market.”

Environmental Audit Clause 2.5
The Environmental audit acknowledged that the law needs to change to stop the large amount of FR chemicals.

Government intervention is necessary to amend a flammability test requirement that no longer matches current manufacturing methods and has led to furniture producers and retailers using large amounts of flame retardant chemicals to comply with the regulations.

3. Yet our fire death statistics are no better than other countries.

(A) Smoke alarms save lives. Sprinkler systems save lives. Stopping smoking reduces fire risk. Not smoking indoors reduces fire risk. These factors have lead to reducing fire death rates (see the chart below).

The chart below compares the UK death rates in fires to the fire death rates in countries that do not have a match test (and do not use FRs in their top fabrics).

Death rates are falling in all countries. The FRs are not the defining factor in the lowering death rates.

{Death rates from fires and burns 1990-2017 comparison between UK, US, France, Belgium, Germany, Netherlands, New Zealand.}


(B) Also see the chart at the end of the European Parliament library briefing, this shows that although the UK uses lots of FR chemicals, the UK fire death statistics are similar to Germany, Italy and the Netherlands who do not treat their fabric with FR chemicals:

(C) Environmental Audit page 25:

UK fire deaths stabilised in the mid-1980s at 12–13 deaths per million. This rate declined following the introduction of the Regulations to 10 deaths per million in the mid-1990s.The rate has continued to decline in recent years. In 2017/18 there were 395 fatalities in Great Britain, a rate of 6 deaths per million. A comparison of deaths from fire in the UK and New Zealand since the 1970s shows a similar rate of decline, despite New Zealand having no furniture flammability regulations. Declines have also been measured in European countries which do not use a match test, only a smoulder test.

In summary, the Government, in the Environmental Audit in 2019 were shown data that the decline in fire deaths in the UK is not because of the large amount of FRs that we use. The same decline is visible in New Zealand where they do not have this FR usage.

(D) A turning point in the American endeavour to overturn their furniture fire regs and replace them with a simpler clearer smoulder test - was the realisation that the FR chemicals in reality only provided a few seconds worth of delay in the onset of fire.

4. These FR chemicals leak from foam, from wadding and from top fabric.


{A 2016 UK Government BEIS impact statement - BEIS = Department for Business Energy and Industrial Strategy}

There is growing body of literature that has linked health and environmental harm with the flame retardant chemicals (brominated, chlorinated and phosphate) used in furniture . Furniture flame retardants can be associated with endocrine disruption, immunotoxicity, cancer, and/ or reproductive and neurological impairments, lowered IQ, and hyperactivity. Flame retardants migrate out of furniture, settle in dust, and are ingested by humans and animals. Young children have the highest blood levels due to hand-to-mouth behaviour. In the USA, a majority of residential fire deaths result from inhalation of toxic gases, and soot and smoke can obscure escape. One study indicates that US fire fighters have high rates of types of cancers associated with dioxin exposure; the dioxins produced when flame retardants burn are believed to contribute. There are some signs in the UK (from press and consumers) that consumer concern over the chemical treatment of furniture is growing here.”

5. They can permeate our skin as we lie on our sofas.

(A) Previous studies had shown that we can ingest FR chemicals, as the sofa acts like a bellows as we sit on it and it puffs the chemicals out of the foam and fabric. This study goes a step further and shows that they permeate our skin aswell. {Abdallah, M.A., Pawar, G., Harrad, S., 2016. Human dermal absorption of chlorinated organophosphate flame retardants; implications for human exposure. Toxicology and Applied Pharmacology, 291, 28-37.}

“Exposure assessment revealed UK adults and toddlers can be exposed to 20.4 and 14.1 ng TCIPP/kg bw/day via contact with furniture fabrics in summer, which is higher than international average exposures via inhalation and dust ingestion for adults and dietary exposure for toddlers.”

Loose tightly woven cotton covers on a sofa that has been FR treated may help to limit dermal exposure when you sit on it, but FR chemicals migrate out of foams and fabrics easily and accumulate in dust. The best solution is furniture that does not use flame retardant chemicals. If you already have flame retardants present in your furniture, vacuum frequently with a HEPA filter, dust with a damp cloth and wash your hands before eating. 

6. Many FRs never degrade.

(A) FRs do not degrade easily and can migrate throughout the environment. 


(B): This study shows that FR chemicals migrate via sweat into the body. { Fireproofing of domestic upholstered furniture: migration of flame retardants and potential risks} Lounis 2019

C): the Stockholm Convention has named certain FRs as Persistent Organic Pollutants (POPs). “Organic” is not a positive term in relation to FRs. It means they are chemicals containing carbon. Carbon forms very strong chemical bonds with halogens (fluorine, bromine and iodine), that do not easily break down in the environment.

7. They build up in our bodies

(A) This study shows that although some FRs have been banned, even in the UK, they are still showing up in breast milk samples.

{Emerging and legacy flame retardants in UK human milk and food suggest slow response to restrictions on use of PBDEs and HBCDD Tao et al 2017} 10.1021/acs.est.5b03904#

Environmental Audit page 23: As flame retardants are found to be persistent, bio-accumulative and toxic to humans and wildlife, certain FRs have been classed as persistent organic pollutants (POPs) and banned under the Stockholm Convention.

8. They build up in our environment

(A) There are studies showing that orca whales, salmon, cats, penguins, porpoises and dolphins all have flame retardants building up in their systems. through-our-wildlife/

(B) There are studies on the build up of FR chemicals in elephant seals.


{Preliminary study of long-range transport of halogenated flame retardants using Antarctic marine mammals Aznar Alemany 2019}

(C) There have also been studies on the build up in the ocean sediments.

Organophosphate Ester Flame Retardants and Plasticizers in Ocean Sediments from the North Pacific to the Arctic Ocean. Environmental Science & Technology, 2017. Ma, Y

(D) Polybrominated Diphenyl Ethers (PBDEs) in Marine Fish and Dietary Exposure in Newfoundland, Babichuk 2022

9. And particularly in our children

(A) {Concentrations of brominated flame retardants in dust from United Kingdom cars, homes, and offices: causes of variability and implications for human exposure: Harrad et al}

(B) Concentrations of Polybrominated Diphenyl Ethers, Hexabromocyclododecanes and Tetrabromobisphenol-A in Breast Milk from United Kingdom Women Do Not Decrease over Twelve Months of Lactation

10. University research on the aftermath of the horrific Grenfell Tower fire has shown that these FR chemicals do not work

We know that the FRs migrate out of the furniture. We do not yet have research that shows whether there is a point in time when the migration is such that the open flame test would no longer be passed.  

*** Source

In an extreme fire situation such as Grenfell Tower, no amount of fire retardant chemical would succeed in preventing a fire.

11. They were originally intended to cause a slight delay in the onset of a fire.


One of the problems we have in changing the law on FRs is that when a tragedy occurs and people die in fires - it is front page news and it is deeply upsetting to all.

However people who suffer the effects of over exposure to toxic FRs do so silently. Perhaps they have difficulty getting pregnant, perhaps their child has ADHD, perhaps their child has a neurological delay.

Source ***

What I am seeking to establish is that in this weighing scales of FR exposure versus potential fire death, the fire death data from California since 2013 has shown us that there has not been an increase in California fire deaths from furniture. Replacing FR chemicals with thick tightly woven furniture upholstery that does not ignite after being exposed to a smouldering fire source or using an interliner under natural fabrics as they have done in the US has not lead to an increase in fire deaths. The new smouldering fire standard in the US has worked.

(See 12 B below for an explanation of US fire death data).


12. But they do not achieve this purpose

(A) Polymer Green Flame Retardants by Papaspyrides  (a published book)

(B) {Furniture Flammability Webinar 2021 analysing the impact of the US change in legislation on fire safety. }

(if this link doesn't work google"furniture flammability webinar October 2021"

In 2014 the US started using more natural fibres or thicker interwoven fabric or interliners for fire safety as an alternative to FR chemicals. The analysis below shows that the interliners work and fire deaths from furniture have not increased.

(C) {Flame Retardants in UK furniture increase smoke toxicity more than they reduce fire growth rate. McKenna 2017}

13. And instead they can cause death by smoke toxicity

Environmental Audit page 26: They found that since the 1990s, the majority of deaths and injuries from fires are caused by the inhalation of toxic smoke. Its study concluded that ‘while we are unlikely to ever have robust data showing how effective flame retardants are in suppressing ignition, it is evident that, once ignition occurs, the presence of flame


retardants has little effect on the fire growth rate, but does have an adverse effect on the smoke toxicity. {Fire Toxicity the Elephant in the Room by Anna Stec at UCLAN University}

14. The scientific community are protesting

In the San Antonio statement scientists from all around the world joined together to question the use of FR chemicals

15. The Cancer charities are protesting

Breast Cancer has a helpful fact sheet on FR chemicals on its website. environment/

16. The environmental charities are protesting

17. For over ten years these impossible regulations have been under “review” by the government, but no change.

18. These FR chemicals are certainly very costly to UK manufacturers.

The flame retardant market is worth over 7.7 billion dollars worldwide, although this covers FR use in building materials and electronics etc as well as furniture.

19. Is the reason that the 1988 Fire regs give the UK manufacturers of furniture and bedding a real life monopoly over the UK market? An overseas manufacturer would have to create a whole separate “UK only” product range full of FRs to do business here.

(A) Efic and Chemtrust initiated a legal action under EU law against the UK government claiming that the effect of the 1988 Fire Regs was to unjustly exclude other European countries from selling furniture into the UK. One effect of Brexit is that this lawsuit has been dropped.

(B) EnvironmentalAudit

“We heard evidence that the test requirements under the Regulations push the use of different flame retardants and make it more difficult for EU based companies to put furniture on the UK market.”

(C) In the 2014 BEIS Consultation clause 33 they refer to the “trade barrier” that the match test creates - by insisting that the UK match test is done over a form of foam that is illegal in the UK, this is a barrier preventing EU companies entering the UK market.

20. Upholsterers who develop endocrine issues?

(A) Exposures, mechanisms, and impacts of endocrine-active flame retardants Dishaw 2014

This study establishes a link between FRs and endocrine issues.

(B) The Environmental Audit page 23 states:

“There is a growing body of research that some flame retardants pose a threat to human health and the environment. The Cancer Prevention and Education Society noted the effects include ‘cancer, neurotoxicity, developmental, behavioural, endocrine, metabolic, reproductive, developmental and allergy.’

21. Fire fighters inhaling toxic fumes and developing cancer?

(A) The Fire Brigade Union and Lancaster University have launched a national fire fighters and cancer and disease registry to record cancers suffered by fire fighters. Elephant%20in%20the%20Room-Stec.pdf

22 The general public who have increased issues of child developmental disorders and infertility?

(A) Urinary concentrations of organophosphate flame retardant metabolites and pregnancy outcomes among women undergoing in vitro fertilisation Courtney C Carignan 2017

B: Breast Cancer UK has a good summary

C: uploads/attachment_data/file/544020/beis-16-12-impact-assessment- amendment-to-the-furniture-and-furnishings-fire-safety- regulations-1988.pdf

(D) The Californian office of Environmental Health Hazard Assessment set up this website to advise on FR chemicals and what to avoid:


23. The next “scope of consultation” document in the latest review of the

1988 Fire Regs will include a “match test” via the back door.


I countersigned a letter from FIDRA to Paul Scully regarding the scope of consultation document. I am not sure this letter has been published but it explains that the timing of inserting the match test into the scope document - when there is no-one to debate that is most unfair.

24. The match test sees a live flame applied to fabric lying over a barely FR treated foam. That means the foam is highly flammable.

(A) Environmental Audit:


“The current FFRs match test (see text box) requires cover fabrics to be tested over highly- flammable (and now illegal in the UK) polyurethane foam fillings. This means the additional flame resistance supplied by the combustion-modified fillings that are present in the final product is not utilised, leading to a higher than necessary ignition resistance standard in the cover fabrics (and more chemicals used to meet it) “ uploads/attachment_data/file/544020/beis-16-12-impact-assessment- amendment-to-the-furniture-and-furnishings-fire-safety- regulations-1988.pdf

25. The whole point of the consultation was to remove the match test and replace it with a smoulder test.

There is a planned consultation on revision to the 1988 law with 46 or so industry bodies and NGOs scheduled for later this year. To insert the match test into the “scope of consultation” document which is being prepared now (with no consultation), seems like decisions are being made outside of the consultation. Once the match test is inserted into the scope of consultation document it will be much harder to remove it.

Again the source is the FIDRA letter to Paul Scully

26. The match test is scientifically proven not to work.

(A) 2016 BEIS Impact Statement on amendment to the 1988 Fire Regs. “weaknesses in the current testing regime mean that the match test may not actually be delivering the desired outcome (ie match resistant furniture)” uploads/attachment_data/file/544020/beis-16-12-impact-assessment- amendment-to-the-furniture-and-furnishings-fire-safety- regulations-1988.pdf

(B) The 2014 BEIS Consultation document states that the current match test doesn’t work because there are unregulated materials in the furniture such as cardboard in the sofa arms which are untreated and make the sofa highly flammable even though the foam and fabric are FR treated. Also the non natural top fabric is tested when laid directly on foam. However in practice most sofas are constructed with polywad between the foam and the fabric. This gives an oxygenated area for the fire to surround the fabric and the FRs are less likely to work. uploads/attachment_data/file/342523/bis-14-980-furniture-fire-safety- regulations-consultation-document-august-2014-protected.docx

27. It has been repealed in the US

(A) After a huge initiative by the people of America, covered by the Washington Post and the Chicago Tribune, in 2013 the US changed their furniture fire laws in California. The whole of the USA has now followed suit and adopted the California TB 117 - 2013 standard. federal-law-expands-furniture-flammability-testing-standard/

(B) This is the current test under US law:

How this works is as follows:

The top cover fabric is tested over standard non FR foam. A cigarette is placed on the chair mock up.

- is it still smouldering 45 minutes later
- is there is a char that is longer than 4.5cm - has it transitioned into flames.

If any of the above happen, the fabric fails (although there is a second chance process of having one more experiment if only one of the problems occurs).

If the fabric fails then an interliner has to be used. The interliners are not chemical so do not use FRs.

(B) These interliners have been successful at delaying fire. {Performance and failure mechanism of fire barriers in full-scale chair mock-ups, Thompson 2021}

28. rejected outright in the EU

(A) Europe has strongly resisted implementing a law like the UK’s match test. No other European country other than England and Northern Ireland have the match test. The European Commission are looking to treat brominated flame retardants as a whole class. This is aimed at halting the unfortunate problem of regrettable substitutions. This is where one individual chemical is banned but is replaced by a similar but slightly different chemical (a regrettable substitution). Treating a type of chemical as a class and banning that class attempts to stop the regrettable substitutions. hazardous-chemicals-sign-things

(B) Environmental Audit page 24:

In addition, [The EU] has proposed a restriction on the sale of children’s products and upholstered furniture with polyurethane foams containing the flame retardants TCEP, TCPP and TDCP. ECHA is due to publish its decision in July 2019.165

(C) The 2014 UK BEIS review states (clause 22) that the European Commission has recently indicated strongly that it will not make any more efforts to raise EU standards while the issue of FRs in furniture remains contentious.

29. Its existence in our legislation can lead to 30% of the mass of a foam cushion being just FR chemicals.

Other information

Where a fabric is fire treated or stain treated, the chemicals used in these treatments can have adverse effects on the upholsterer who works on them, take a look at the open letter above and I encourage you to sign.

If you have experienced any problems working with these FR chemicals do please share your story, it will help persuade a University epidemiologist that the harm to upholsterers of FR chemicals is worth further research -

I have found these pieces of research informative and wanted to share them:

This is the UK Government Environmental Audit Committee Report that concludes that flame retardant chemicals in furniture are persistent organic pollutants and substances of very high concern.

Breast Cancer UK have a helpful summary of the risk of flame retardant chemicals.

HBO released a movie in the US called Toxic Hot Seat. It's available to us on Apple TV (but for £7). This documentary together with many articles written by the Chicago Tribune initiated a huge change in the US fire safety and furniture laws - they no longer require the open flame test, they now require the smoulder test. We would like to see this change in the UK. This US law firm explains the change in the US quite succinctly.

This research article shows that we ingest flame retardant chemicals from house dust.

Professor Hull at UCLAN university compared the burning of a UK sofa (high in flame retardant chemicals) to the burning of a European sofa (not so high).

Professor Abdallah at Birmingham University has concluded that toddlers absorb most of the flame retardant chemical by crawling all over sofas and sticking their hands in their mouths.


This US research article shows that an effective barrier cloth laid over foam with no FRs in the foam and no FRs in the barrier cloth can delay the onset of fire by up to19 minutes.



Ms Delyth Fetherston-Dilke Delyth Upholstery

Dear Ms Fetherston-Dilke,

Paul Scully MP

Parliamentary Under-Secretary of State

Department for Business, Energy & Industrial Strategy
1 Victoria Street


T +44 (0) 20 7215 5000 E W

Our ref: MCB2022/10951 17 May 2022

Thank you for your email of 4 May 2022, sharing your Open Letter dated 3 April that sets out your concerns about the use of flame retardant chemicals in UK domestic upholstered furniture and furnishings.

The Government considers the safety of consumers to be a priority, and I feel strongly that consumers should have confidence that the products in their homes are produced to rigorous safety requirements.

The Furniture and Furnishings (Fire) (Safety) Regulations 1988 (The FFRs) set strict furniture fire safety regulations to prevent ignition and to increase the time available to escape should items ignite, which is critical in many fire scenarios. The FFRs do not stipulate the use of chemical flame retardants (CFRs) to ensure products are flame retardant but it is understood that manufacturers often use CFRs deemed safe under the UK’s chemical regulatory regime, as the most cost-effective solution to meeting the ignitability tests set out in the Regulations.

However, manufacturers and upholsterers can make use of inherently flame-retardant materials and products that deliver consumer safety from fires without the need for CFRs. The Government welcomes innovative approaches that deliver safe outcomes for consumers.

In July 2019, the Government announced it would develop a new approach to the Regulations based on essential safety requirements. The new approach aims to maintain and improve fire safety while facilitating a reduction in the use of CFRs. It is vital that the furniture fire safety regime reflects modern domestic fire safety risks and considers the growing concern about the risks associated with exposure to CFRs.

The recommendations made by the Environmental Audit Committee following its inquiry into Toxic Chemicals in Everyday life in 2019 are being considered as part of the review of the existing regime and development of the new approach. The new approach will introduce a package of measures to enable and encourage a reduction in the use of CFRs as a means of making furniture fire resistant.

The new legislation will be supported by new voluntary British Standards which are being developed independently by BSI in partnership with a wide range of stakeholders, including those in industry, fire safety experts and consumer representatives. The new British Standards are being designed to support businesses to meet those essential safety requirements, and it is the role of the BSI committee to consider how manufacturers and upholsterers can use those standards to evidence that they meet the essential safety requirements.

The Government is planning to consult on the new policy and draft regulations this year. We encourage you, and all interested parties, to provide feedback during the consultation and all views are welcome.

Thank you once again for taking the time to write to me on this important issue. Yours sincerely,


Minister for Small Business, Consumers & Labour Markets and Minister for London

IMG_4473 2.jpg
bottom of page